QUOTA NOTES

Newsletter of Proportional Representation Society of Australia Inc.

QN2026C           September 2026 www.prsa.org.au

UK Prime Minister’s pledge to use proportional

representation to elect its House of Commons

The elections in 2023 for the State
Duma of the Russian Federation

Bid to have High Court invalidate Act’s
above-the-line provision for Senate votes

Proposal to change Fiji's unicameral
Parliament from party list PR to MMP

List of Issues of Quota Notes

UK Prime Minister’s pledge to use proportional
representation to elect its House of Commons

The pledge - that he was “… committed to proportional representation …” - made in May 2026 by the Rt Hon Andy Burnham PC, before he won a by-election and thus re-entered the UK’s House of Commons, was included in an article in QN2026B.

Unfortunately, Mr Burnham gave no indication of whether his commitment then to a system of proportional representation was for a direct PR-STV system like Hare-Clark, or instead some form of indirect election of MPs using a party list system.

He did, however, reportedly say - in a speech he gave later, in his new role as Prime Minister of the United Kingdom, on 23 September 2026, at the Labour Party’s Annual Conference - “We will contest the next election with a manifesto commitment to change the electoral system so that everyone’s vote counts and everyone’s voice is heard.”

The BBC reported about Mr Burnham that, “In his first party conference speech as Prime Minister, he announced plans for a national commission to explore options for electoral reform.” It might not be PR-STV.

The elections in 2026 for the State

Duma of the Russian Federation

In September 2026, elections were held, throughout the Russian Federation, for the State Duma. The Duma is the lower house of the Federal Assembly, which is the parliament of the Russian Federation.

The upper house is the Federal Council, which is indirectly elected by prescribed body politics within the Federation. Russia’s President is elected - nominally by direct popular election - using plurality counting, on a different date from the Duma.

The Duma elections use parallel voting, which is different from a Mixed-Member Proportional system. Half of the Duma’s 450 seats are elected from a single nation-wide electoral district using a party-list form of proportional representation. The other half are elected from single-member districts using plurality counting. See Table 1 below.

Party	Party list half of the seats		Single-member half of the seats %	Total seats %
	% votes	% seats
United Russia	59.0	62.2	92.9	77.6
Communist Party	13.7	14.2	2.2	8.2
Liberal Democratic	9.0	9.3	0.9	5.1
A Just Russia	5.4	5.8	1.8	4.2
Rodina	0.7	0.0	0.4	3.8
Independents	0.0	0.0	1.8	0.9
Others	12.2	0.0	0.0	0.0
TOTALS	100.0	100.0	100.0	100.0

Table 1: Results of the Duma’s 2026 elections

The turnout was 59.6% and the informal vote was 1.4%. Reactions to the results, both nationally and internationally, showed considerable concern about the fairness, and even the legality, of many aspects of the conduct of the elections for the Duma.

The previous Duma elections, in 2021, had no single-member electoral districts. Like Israel, and the Netherlands, it used then a party list form of proportional representation with the whole nation as a single electoral district.

Bid to have High Court invalidate Act’s above-the-line provision for Senate votes

PRSA Inc. received a telephone call and an email recently from a Mr Kevin Loughrey informing it of an application he had lodged with the High Court of Australia seeking a declaration from it.

His email included a copy of his application. It argued that the provisions of the Commonwealth Electoral Act 1918 for the above-the-line option for Senate elections were invalid on the ground that they are inconsistent with Section 7 of the Australian Constitution, whose first sentence mandates that senators for a State be directly chosen by the people of the State.

If his application were to have been granted, it would appear to have required the overturning of the Court’s longstanding 1984 decision, in the McKenzie case. The High Court’s website reveals that Mr Loughrey made his application on 23 May 2026. The Court assigned to the case the Case Title “Loughrey v. Commonwealth of Australia”, and the Case No. “S42/2026”.

Some of Mr Loughrey’s background appears here, including a hyperlink to his website. He told PRSA Inc. that he is intending to stand as a One Nation Party candidate at the 2027 NSW State election, and that he advocates electoral reform by using the Borda points system.

Points systems are certainly not supported by PRSA Inc, so it will email him to give him that hyperlink explaining the major faults of points systems, which require voters to mark preferences, but do not use transferable voting.

A reading of his application can give the impression that it could have presented the Court with a good case for what PRSA Inc. considers would be a welcome interpretation of the requirement for senators to be “directly chosen by the people of the State” as stated in that Section 7.

Nevertheless, until an applicant is willing to comply with an order to pay the Commonwealth’s costs, as well as their own, it seems unlikely that the Court will receive an application to revisit this matter. Mr Loughrey has since discontinued his application, as he failed to obtain funding for it.

It could be that if a well-resourced organization, such as Simon Holmes à Court’s group, Climate 200, were to unite with other groups seeking the repeal of the remaining above-the-line provision, Inc, it might be possible to undertake a properly-resourced and funded further application to the High Court on this matter.

The Commonwealth Parliament repealed, in 2016, the Group Voting Ticket contrivance that, as part of the above-the-line provision, it had imposed in 1983. It could be the Commonwealth Parliament that eventually repeals the remaining above-the-line provision.

Proposal to change Fiji’s unicameral Parliament from party list PR to MMP

The Constitutional Review Commission of Fiji was established by the Government of Fiji to consider whether the electoral system used for Fiji’s 55-member unicameral Parliament, which is an open party-list form of proportional representation using a single nation-wide electoral district, should be altered.

Its recent report has recommended that Fiji’s present system should be replaced by a Mixed-Member Proportional system, with 26 single-member seats filled by direct election and 15 seats filled indirectly from party lists, in order to make the overall composition of the Parliament match the proportion of votes cast for the various political parties.

If the Commission had instead recommended a Hare-Clark system, future Fijian Parliaments could be elected from eleven 5-member districts. That would give all voters, rather than just small party pre-selection committees, power to decide directly who the voters’ representatives would be.

It would also result in the percentage of MPs from the various parties broadly matching the percentage of voters supporting those parties’ candidates.

© 2026 Proportional Representation Society of Australia Inc.

ABN 31 010 090 247    A0048538N Victoria

President: Dr Jeremy Lawrence     pre@prsa.org.au